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Documentation and Waste

Documentation regarding lead abatement projects shall be submitted to the university in accordance with the current "Hazardous Material Abatement Services" contract, which is held by the Division of Campus Planning, Infrastructure, and Facilities.

Written Abatement Plan

A written plan of all work procedures that will be used in the repair, removal, and/or demolition of materials containing lead shall be submitted to the owner for review and approval at least 10 working days in advance of the first project performed under the "Hazardous Material Abatement Services" contract. Plans are submitted to the contract review committee during the pre-bid process. Environmental Health & Safety shall review the plans and provide comments as part of that committee, as necessary, prior to the contract being awarded.

Contractor Final Report

Within 45 days of completion of each lead abatement project, the contractor shall submit to the university (per the contract) a final report consisting of the following:

  • Start and finish date of work performed
  • Location of work - building and room number
  • Copies of current licenses for contractor personnel on site:
    • Virginia General Contractors License
    • Virginia Lead Paint Abatement Contractor License
    • Supervisor lead certificates/licenses
    • Worker lead training certificates/licenses
    • Statement the worker(s) is actively involved in a company employee medical surveillance program
    • Total lead blood level below 30 ug/dl as verified by doctor's evaluation with laboratory results
    • Form AR 2 Worker Release
    • Form AR 3 Respiratory Protection
    • Copies of each employee's INS Form I-9, Employment Eligibility Verification Form, and documents used to complete
      • No social security numbers
  • Copies of all state and federal notifications (if applicable) and permits pertaining to the particular project
  • Copies of a daily log showing the following:
    • Name
    • Date entering and leaving time
    • Company or agency represented
    • Reason for entry for all persons entering the work area
  • Results of all air samples 
  • Landfill documentation and waste manifests, as applicable
  • Copies of all Toxicity Characteristic Leaching Procedure (TCLP) testing performed by the contractor for waste disposal

This documentation shall be retained with the project files (preferably electronically), and shall be made available to Environmental Health & Safety or regulatory authorities upon request.

Waste Handling

On projects where lead-containing materials will be disturbed or removed, the university project manager shall contact the EHS Hazardous Waste Manager at 540-231-2982 to determine disposal requirements during the design phase of the project.

Where lead-containing materials will be disposed, the waste stream shall be TCLP-tested (if attached to a substrate) to determine disposal requirements. The costs associated with TCLP testing and waste disposal shall be covered by the project that disturbs these materials.

Lead paint chip waste does not require a TCLP Test, but shall be disposed of through EHS as hazardous waste.

EHS shall ensure all documentation requirements are met, and sign any associated waste manifests.